UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY

Tanya Beals, on behalf of herself and all
other persons similarly situated

VS.

Bank of America, N.A, BAC Home Loans
Servicing, L.P., a wholly owned subsidiary
of Bank of America, N.A., LaSalle Bank,
N.A., John Does 1-10

Excerpts:

Defendants Have Consistently Demonstrated a Willful Disregard
for the Procedural Safeguards Entitled to All Borrowers

Defendants Routinely Act in Bad Faith and in Breach of Contractual
Obligations During the Course of their Settlement Negotiations with Plaintiffs

FIRST COUNT
(Fraud)

SECOND COUNT
(Violation of the New Jersey Consumer Fraud Act
codified at N.J.S.A. §§ 56.8-1, et. seq.(NJCFA))

THIRD COUNT
(Breach of Contract)

FOURTH COUNT
(Breach of the Covenant of Good Faith and Fair Dealing)

FIFTH COUNT
(BREACH OF IMPLIED CONTRACT)

SIXTH COUNT
(Quantum Meruit)

SEVENTH COUNT
(Violation of the New Jersey Fair Foreclosure Act)

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